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# 15 U.S.C. 1, Trusts, etc., in restraint of trade illegal; penalty: How Federal Cases Ended, FY2016–2025
- URL: https://www.bodiesburied.com/trends/federal-statute-15-usc-1-case-outcomes/
- Published: 2026-11-03T06:55:46.000Z
- Updated: 2026-11-03T06:55:46.000Z
- Description: Of the 43 federal trials in which 15 U.S.C. 1 was the most serious charge in fiscal years 2016 to 2025, 30 ended in an acquittal (70%). Across all 329 cases, 253 defendants (77%) pleaded guilty. Of the 266 convicted, 132 (50%) received a prison term on that charge, with a median term of 6 months.
- Author: Jocelyn C. Stewart
- Tags: Understanding Trends, Federal

[Trends](https://www.bodiesburied.com/trends/) › [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) › 15 U.S.C. 1

**In brief:** Of the 43 federal trials in which 15 U.S.C. 1 was the most serious charge in fiscal years 2016 to 2025, 30 ended in an acquittal (70%). Across all 329 cases, 253 defendants (77%) pleaded guilty. Of the 266 convicted, 132 (50%) received a prison term on that charge, with a median term of 6 months.

Updated November 3, 2026 · Sources: U.S. Sentencing Commission and Federal Judicial Center, fiscal years 2016–2025

This post uses the Federal Judicial Center's records of 329 federal defendants whose cases ended in fiscal years 2016 to 2025\. The series also draws on the U.S. Sentencing Commission's records of 659,036 people sentenced in fiscal years 2016 to 2025\. It is part of the [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) series, which builds on [Military Moves Toward Sentencing Guidelines to Mirror the Federal System](https://www.bodiesburied.com/trends/military-sentencing-guidelines-federal-system/). How the numbers were built: [How the Federal Comparison Data Was Built](https://www.bodiesburied.com/trends/federal-data-methodology/).

## Trial Results Under This Section

A trial was held for 43 defendants (13%). Juries heard 35 of those trials and acquitted in 24 (69%). Judges sitting alone heard 8 and acquitted in 6 of 8.

The acquittal rate counts only trials that reached a verdict. It does not include the defendants who pleaded guilty or whose charges were dismissed.

## The Section and the Data

Title 15, section 1 of the U.S. Code is headed "Trusts, etc., in restraint of trade illegal; penalty." This post reports how the federal criminal cases under that section ended.

The source is the Federal Judicial Center. It counts 329 defendants whose cases ended in fiscal years 2016 to 2025 with a most serious charge under this section at the end of the case. Dismissals and acquittals are counted, not only sentencings. Every one of the charges was a felony.

## Pleas, Dismissals, and Convictions

Guilty pleas ended 253 cases (77%). Dismissals ended 33 (10%). A dismissal in these records can include a case the government dropped after the person pleaded guilty in another case.

By plea or verdict, 266 of the 329 defendants (81%) were convicted.

## Prison Terms

A prison term on this charge was given to 132 of the 266 people convicted (50%). The rest received no prison term on this count.

Among terms of 1 month or more, the median was 6 months. The median is the middle term in ranked order and does not show how short or long the other terms were.

## Which Kind of Lawyer Was Recorded?

Private (retained) counsel represented 292 defendants (89%). CJA panel attorneys, private lawyers appointed by the court, represented 18 (5%). Federal public or community defenders represented 3, and 2 defendants represented themselves.

With private counsel, 80% pleaded guilty, 7% were dismissed, and 38 went to trial, with 28 acquittals (74%). The CJA panel group had 4 trials and 1 acquittal. The federal defender group had 1 trial, which ended in an acquittal.

These numbers describe groups of cases, not the quality of lawyers. Retained and appointed counsel tend to represent people facing different charges and circumstances, and the appointed groups here are very small.

| Type of counsel at the end of the case | Defendants | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
| -------------------------------------- | ---------- | -------------- | --------- | ------ | ------------------ |
| Federal public or community defender   | 3          | 2 of 3         | 0 of 3    | 1      | 1 (1 of 1)         |
| CJA panel attorney                     | 18         | 78%            | 0%        | 4      | 1 (1 of 4)         |
| Private (retained) counsel             | 292        | 80%            | 7%        | 38     | 28 (74%)           |
| Self-represented                       | 2          | 2 of 2         | 0 of 2    | 0      | 0                  |

## Year to Year

Yearly counts were small, from 12 cases in fiscal year 2021 to 67 in fiscal year 2018\. Trials were concentrated in a few years. In fiscal year 2023, 14 cases went to trial and 13 ended in an acquittal (93%). In fiscal year 2022, 7 of 8 trials ended in an acquittal.

Fiscal years 2021 and 2024 had no trials. Counts this small do not show a trend.

| Fiscal year | Cases ended | Pleaded guilty | Dismissed | Trials | Acquitted at trial |
| ----------- | ----------- | -------------- | --------- | ------ | ------------------ |
| 2016        | 43          | 88%            | 2%        | 4      | 4 (4 of 4)         |
| 2017        | 48          | 88%            | 4%        | 4      | 1 (1 of 4)         |
| 2018        | 67          | 88%            | 3%        | 6      | 2 (2 of 6)         |
| 2019        | 32          | 84%            | 6%        | 3      | 3 (3 of 3)         |
| 2020        | 17          | 88%            | 0%        | 2      | 0 (0 of 2)         |
| 2021        | 12          | 67%            | 33%       | 0      | 0                  |
| 2022        | 22          | 36%            | 27%       | 8      | 7 (7 of 8)         |
| 2023        | 46          | 59%            | 11%       | 14     | 13 (93%)           |
| 2024        | 18          | 56%            | 44%       | 0      | 0                  |
| 2025        | 24          | 79%            | 13%       | 2      | 0 (0 of 2)         |

## What the Data Cannot Tell

The records group cases by the most serious charge at the end. They contain no evidence, no case facts, and no reasons for dismissals or verdicts. The approved crosswalk lists no close court-martial counterpart for this section, so the post covers federal cases only.

### How We Counted

Every federal defendant whose case ended in fiscal years 2016 to 2025 and whose most serious charge at the end of the case (TTITLE1) was under 15 U.S.C. 1, any subsection (329), Federal Judicial Center, counted as in the federal courts' Table D-4\. Type of counsel is TCOUNSEL; labels from the FJC criminal codebook. Section heading from the U.S. Code as published by the Office of the Law Revision Counsel (release point 119-136).

Federal fiscal years run from October 1 to September 30\. No person, judge, or lawyer is identified in any of these records.

### What to Keep in Mind

**Who is in each set of numbers.** The federal sentencing numbers come from the U.S. Sentencing Commission. They count only people who were convicted and sentenced in federal district court. People whose cases were dismissed or who were acquitted are not in them. The military numbers come from court-martial results, which include acquittals. To compare acquittal or dismissal rates, the federal side uses a different source: the Federal Judicial Center's case data, which counts every defendant whose case ended.

**How "plea" and "trial" are counted.** In the federal sentencing numbers, "trial" means the person was convicted after a trial, including people who pleaded guilty to some counts and went to trial on others. People acquitted at trial are not in these numbers at all (see "Who is in each set of numbers"). In the federal case data, the trial rate counts both convictions and acquittals at trial among all defendants whose cases ended, including dismissed cases. Military numbers count contested cases that reached a verdict. These denominators are not the same, and each post states the one it uses.

**Time periods.** Federal numbers are by federal fiscal year (October 1 to September 30), based on the sentencing date. The military numbers are by trial date. Neither source has the date of the offense, so a change in law shows up in either data set gradually.

**Type of counsel describes groups of cases, not lawyers.** The Federal Judicial Center records the type of counsel at the end of the case. Defendants who hire a lawyer differ from defendants who receive an appointed lawyer in their charges, criminal history, and circumstances, and some defendants change lawyers during a case. Differences in outcomes by type of counsel therefore cannot be credited to the type of lawyer.

## Related Analysis

- [Military Moves Toward Sentencing Guidelines to Mirror the Federal System](https://www.bodiesburied.com/trends/military-sentencing-guidelines-federal-system/) (the background article)
- [Federal Prosecution Analysis](https://www.bodiesburied.com/trends/federal/) (all federal posts)
- [How the Federal Comparison Data Was Built](https://www.bodiesburied.com/trends/federal-data-methodology/) (sources and method)
- [Appointed vs. Retained Lawyers in Federal Criminal Cases: How Cases Ended, 2016–2025](https://www.bodiesburied.com/trends/federal-appointed-vs-retained-counsel-outcomes/)
- [Are Courts-Martial More Likely to End in Acquittal Than Federal Trials?](https://www.bodiesburied.com/trends/federal-trial-acquittal-rates-vs-courts-martial/)
- [U.S. Sentencing Commission, Individual Offender Datafiles](https://www.ussc.gov/research/datafiles/commission-datafiles?ref=bodiesburied.com) (source)
- [Federal Judicial Center, Integrated Database (criminal defendants)](https://www.fjc.gov/research/idb?ref=bodiesburied.com) (source)

**About the author.** Jocelyn C. Stewart is a retired Army JAG with more than 24 years of trying courts-martial and more than 200 jury trials. She hosts *Where All The Bodies Are Buried* and runs the [Law Office of Jocelyn C. Stewart](https://www.ucmj-defender.com/?ref=bodiesburied.com). This analysis is for education and information only. It is not legal advice, and every case is different.